Bra grejjer från Holland:
http://staff.science.uva.nl/~noordend/publications/DPR-GvN-final.pdf
Alldeles färskt: Guido van't Noordende, Informatics Institute,
University of Amsterdam, April 30, 2013
//Erik
*Summary of main points**
*
- Definitions of anonymous or pseudonymous data are unnecessary if a
good definition of personal data exists. Currently proposed definitions
of anonymous and pseudonymous data focus narrowly on removing directly
identifiable features from microdata, thus ignoring significant risks of
re-identifyability of the remaining data.
- Current Article 83 creates an exemption from DPR rules that allows
usage of data for "historic, statistical, and scientific research" even
if identifiable, without consent. This is too lenient, particularly
given the broad application of Article 83 within the DPR.
- Medical information looses its special protection in the DPR (compared
to 95/46/EC) under the original definition of Article 81 in the
commission's proposal. A consent requirement should be included in
Article 81(2). Also, Article 83 should not permit for processing of
special categories of information for historical, statistical and
scientific research without explicit consent.
- Re-identification mechanisms have been described for years, and it has
been shown that combination of "anonymised" (or pseudonymised) data with
other (background) information is straightforward. If due to new DPR
regulations more and more "anonymised" micro-information becomes
available, this problem is exacerbated, as re-identifcation and/or
linkage of this information with other information becomes even more
straightforward.
- Pseudonymised information, due to its inherent property of linkability
and longitudinal stability (i.e., being the same over time), may bring
additional risks compared to using anonymous data. Pseudonymization is
usable as a tool for securing information during processing, but should
not be used as a means to escape DPR rules such as accountability and
transparency.